Partner Non-Compliance Policy
Reviewed: March 2024

CONTENTS
OUR COMMITMENT

03

DEFINITIONS03

SCOPE OF THE POLICY

04

IMPLEMENTATION

04

RESULTING IMPLICATIONS FOR DIRECT BUSINESS ASSOCIATES

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BRIBERY

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OUR COMMITMENT
Burberry strives to work with its Business Associates to ensure compliancewith the Responsible Business Principles and, where applicable, any Letter ofUndertaking. Burberry may take action in respect of Business Associates that
do not demonstrate sufficient commitment to or are in breach of (orreasonably suspected of being), the standards of the Responsible Business
Principles or, where applicable, the terms of any Letter of Undertaking. Thisaction may include terminating Burberry’s business relationship with theBusiness Associate or requiring that the relevant Business Associate is nolonger used by other Business Associates in any part of the supply of products
or services to Burberry.

Burberry’s Partner Non-Compliance Policy is designed to give a Business
Associate a reasonable amount of time to rectify the critical issues tominimise any potential and/or detrimental impact on the workers’ livelihoods,
subject always to and without prejudice to, any rights which Burberry may
have in contract or otherwise.
DEFINITIONS“Business Associates” refers to any individual, entity, business, company,partnership or any other body or group associated with Burberry including,
without limitation, any such individual, entity, business, company, partnershipor any other body or group supplying products, goods, raw materials,components, services, real estate or anything else, directly or indirectly, to any
member of the Burberry Group or otherwise working directly or indirectlywith or on behalf of any member of the Burberry Group. This also includes
any person (an “Indirect Supplier”) providing products, goods, raw materials,components, services or anything else to (i) a direct supplier of Burberry or
any other member of the Burberry Group or (ii) any other Indirect Supplier.
Burberry Associates include, without limitation, the following:• finished goods vendors• raw material and/or component suppliers• people or entities who carry out any processing on any goods directly
or indirectly supplied to Burberry, including sites at which thisprocessing takes place• non-stock vendors• construction contractors (and their construction sites)• franchisees• licensees• joint-venture partners• consultants• contractors• wholesale customers• service providers, including circular business model service platforms• agents• landlords, and• any subcontractor of the above

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All Business Associates must comply with the Responsible Business Principles
and such compliance is a condition of working with Burberry (whether
directly or indirectly).
“First Tier Business Associate” refers to a Business Associate that directly
contracts with Burberry for supplying products, goods, raw materials,components, services, real estate or anything else (but, for the avoidance ofdoubt, excludes Indirect Suppliers).
References to ‘unauthorised subcontracting’ applies to any situation in which
any part of Burberry production has been outsourced to a Business Associatethat has not been previously approved in writing by the Burberry
Responsibility team (‘‘Unauthorised Subcontracting’’).
“Burberry-branded and non-branded goods” refers to the manufacture or themanufacturing processes relating to fabric, materials, trimmings, rawmaterials, clothing accessories and finished goods, including Beauty andFragrance.
“Corrective action plan (CAP)” refers to the document listing the nonconformities identified during an ethical trade audit and indicating the steps
that the Business Associate will undertake to solve them (the “correctiveactions”) and the deadlines for implementation.
SCOPE OF THE POLICYThe Partner Non-Compliance Policy applies to all Business Associates
including without limitation Business Associates involved in the sourcing or
manufacture of raw materials for incorporation into any Burberry-branded andnon-branded goods.

Should a Business Associate breach any of the terms of the Responsible
Business Principles or, if applicable, a Letter of Undertaking, Burberry shall beentitled to terminate the business relationship.
This Policy will be applied to the Business Associate where the noncompliance to the Responsible Business Principles has been identified. In thecase of Unauthorised Subcontracting where the Business Associate outsourced
production of goods or services, the Business Associate who outsourced theproduction will be subject to the Burberry Partner Non-Compliance Policy. In
both cases the communication will be directly with the Business Associate.
IMPLEMENTATION
Burberry seeks to work with Business Associates that demonstrate continuousimprovement and transparency in their compliance with the Responsible
Business Principles. In some cases, where a Business Associate fails to show
continuous improvement or transparency with regard to the Responsible
Business Principles and/or in the event of a critical issue, Burberry retains
sole discretion to implement a number of actions including, but not limited to:suspension of orders, reduction of orders, cancellation of existing orders,removing all current production and even terminating its business relationship

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with the Business Associate (as it deems appropriate in the circumstances), inaccordance with the process set out below.
Burberry expects all instances of non-compliance, regardless of theseriousness thereof, to be rectified within such specific period of time as may
be set by Burberry in its sole discretion.
Without prejudice to any other rights or remedies available to Burberry, thefollowing is the usual process that shall be followed, other than in exceptional
circumstances, in the event that critical issues are identified at the businessfacilities of or in respect of the Business Associate:
1. 1st non-compliance
1.1 If Burberry identifies a critical non-compliance(s) in respect of the BusinessAssociate., the Business Associate will be sent an audit report and will berequired to submit to Burberry Responsibility team a corrective action plan(“CAP”) for approval.

1.2 If Burberry identifies a severe critical non-compliance(s) in respect of theBusiness Associate, the Business Associate will be sent an audit report and will
be required to submit to Burberry Responsibility team a corrective action plan(“CAP”) for approval. In this instance Burberry may also request that all
production and raw materials are immediately removed.
1.3 In the case of Unauthorised Subcontracting, the Business Associate will
receive a warning letter and all production and raw materials should be
immediately removed1. The audit report and/or CAP and/or warning letter willbe the first warning for the relevant Business Associate to comply with
Burberry’s Responsible Business Principles.
1.4 Burberry expects the Business Associate to remedy the non-compliancewithin the time frame set by Burberry2 and monitors remediation throughregular onsite visits.
2. 2nd non-compliance
2.1 If during a follow up visit, the same or new critical non-compliance isidentified at the Business Associate’s facility, Burberry may, in its discretion,issue a notice of exit. If a notice of exit is issued, no new orders may beallocated, and the Business Associate will not be considered for re-audit within
18 months.

2.2 Facilities owned by a First Tier Business Associate may receive anadditional follow up visit before notice to exit is issued.
2.3 In the case of Unauthorised Subcontracting, all production and rawmaterials should be immediately removed. All decisions will be escalated tothe Ethical Assurance Sub-Committee.
RESULTING IMPLICATIONS FOR DIRECT BUSINESS ASSOCIATES
Burberry strives to create a culture of responsibility within its supply chain
and business relationships, with direct Business Associates held accountable

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for the ethical trading performance of the facilities they partner with. First
Tier Business Associates are expected to cascade Burberry’s Responsible
Business Principles throughout its value chain. Where critical findings areidentified, Burberry expects all Business Associates to work in partnershipwith Burberry to rectify issues in a timely manner.
If critical findings are identified at a subcontractor’s facility, this may impact
the business allocated to the impacted Business Associate(s).
BRIBERY
In the case of any bribery allegation reported to Burberry, the case will beescalated to Burberry’s General Counsel and the Burberry Asset and Profit
Protection team to be investigated. Depending on the outcome, theinvestigation may result in immediate termination of business.

Please refer to Burberry’s Anti-Bribery and Corruption Policy and as part ofBurberry’s Responsible Business Principles.

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